Completed by:

Vale Internal

Appendix 4

Initial Risk Assessment

Questionnaire
Company Name and Location: KARYA PRATAMA / Jl. Letmud Sarniem Perum Bukit Sari Asri Residence Blok B No.04
RT.34 Kel. Kenali Asam Bawah Jambi (Kota) Jambi Indonesia

Registration Number or Tax ID No.1 : 026030064331000

Contact Name Suhawi Email suhawi.74n@gmail.com

Phone: 081319998735
Contract Name: Project Name:

As part of Vale’s Global Anti-Corruption Program, please answer the following questions according to the services,
materials and/or equipment that are supplied/may be supplied by the Company to Vale. This includes all subcontractors2,
agents or similar that will be used by the Company in connection with such supply.

1. Is the Company directly or indirectly controlled or represented by — or in any way connected to — a Government
Official or a Government Authority? (Please see the definitions at the end of this document.)

Yes No X

If Yes, please provide details:

2. Will the Company have contact with a Government Official or a Government Authority on Vale’s behalf, on Vale’s
benefit or in the interest of Vale, as:
(a)sales agents, customer representatives or brokers;
(b)port handling services;
(c) political advisors or consultants;
(d)seeking to obtain government licenses, rights-of-way or other permits and approvals; or
(e)customs brokers or tax advisors?
X
Yes No

If Yes, please provide details:

3. Will the Company have contact with any Government Official or Government Authority in circumstances not
covered by item 2 above?

X
Yes No

If Yes, please provide details:

1 For partnerships, trusts or sole traders, please provide equivalent details and evidence.
2 Note that any subcontractor must be previously approved by Vale.

November 2016
4. Will the Company provide consultancy or advisory services to Vale or its affiliates?

Yes No X

If Yes, please provide details:

5. If you responded “No” to Question 4, please select “not applicable” below.

If you responded “Yes” to Question 4, please consider the
following: Regarding the Company’s provisions of services to
Vale including:
(a)technical assistance, advice or support (including I.T.) in relation to the provision of your services or goods; or
(b)opinions or advice related to legal, technical, organizational or managerial matters;
Please confirm that the provision of these specific services is in no way associated or affiliated with a
Government Official or a Government Authority:

Yes, I confirm No, I cannot confirm Not applicable X

If No, please provide details:

6. Will the company receive a success fee or commission for achieving commercial or legal objectives on Vale’s
behalf, on Vale’s benefit or in the interest of Vale?
X
Yes No

If Yes, please provide details:

Submitted by: ...........................................................................................................................................................

Title: ..................................................................................................... Date: 07-Oktober-2019

Definitions:
Government Official means:
• anyone who, albeit on a temporary basis and with no compensation, occupies
a position, is employed by, or exercises a public function in government
entities, legal entities controlled directly or indirectly by public entities
(including state owned enterprises), be them national or foreign
• an employee, officer or representative of, or any person otherwise
acting in an official capacity for or on behalf of, a Government
Authority (as defined below);
• a member of an assembly or a committee, or employees engaged in
the performance of public duties in accordance with applicable laws
and regulations;
• a legislative, administrative, or judicial official, regardless of whether
elected or appointed;
• an officer of, or individual who holds a position in, a political party;
• a candidate for political office;
• an individual who holds any other official, ceremonial, or other appointed
or inherited position with a government or any of its agencies;
• an officer or employee of an international organization (including,
without limitation, the World Bank, United Nations, International
Monetary Fund and OECD);
• a person who is, or holds himself out to be, an intermediary acting on
behalf of a government official; or
• a person who, although not a public officer, is determined by
applicable legislation to be equivalent to a public officer.
• an employee of a state-owned company, including those of
state-controlled companies.
Governmental Authority means:
• a Governmental Entity: any supra national, national, state,
municipal or local government (including any court, administrative
agency or commission or other governmental authority) or any
arbitrator or any quasi governmental or private body exercising
any regulatory, judicial or other governmental or quasi
governmental powers.
• an instrumentality, board, commission, court, or agency, whether
civilian or military, of any Governmental Entity, however
constituted;
• an association, organization, business or enterprise which is owned or
controlled, directly or indirectly, by a Governmental Entity including a
state-owned company or a state-owned enterprise; or
• a political part.

November 2016